Code of Ethics

Velocity’s Code of Ethics sets forth the guiding principles by which we operate our company and conduct our daily business with our stockholders, customers, vendors and with each other. These principles apply to all of the directors, officers and employees of the Company. Velocity directors and officers are committed to and involved in consumer compliance.

PRINCIPLES

Complying with Laws, Regulations, Policies and Procedures

All directors, officers and employees of the Company are expected to understand, respect and comply with all of the laws, regulations, policies and procedures that apply to them in their positions with the Company. This includes all of the relevant consumer compliance laws that govern our industry, including but not limited to FDCPA, GLBA, HIPAA, FCRA, SCRA, TCPA, FACT, EFT, TILA, ECOA, REG-E and UDAAP. Employees are responsible for talking to their supervisors to determine which laws, regulations and Company policies apply to their position and what training is necessary to understand and comply with them. Directors, officers and employees are directed to specific policies and procedures available to persons they supervise.

All Velocity vendors are expected to adhere to the high business standards set forth in Velocity’s code of ethics.